ML20235V479
| ML20235V479 | |
| Person / Time | |
|---|---|
| Issue date: | 10/07/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1616, NUDOCS 8710150181 | |
| Download: ML20235V479 (103) | |
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TRANSCRIPT OF PROCEEDINGS UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l
SUBCOMMITTEE ON SAFETY PHILOSOPHY, TECHNOLOGY AND CRITERIA J
l In the Matter of:
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SAFETY PHILOSOPHY, TECHNOLOGY
)
AND CRITERIA SUBCOMMITTEE MEETING
)
1
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Pages:
1 through 86 3
f Place:
Washington, D.C.
j 30i;0ci.z Date:
October 7, 1987 Heritage Reporting Corporation Official Reporters 12201. Street. N.W.
Washington. D.C. 20005 (202) 628 4888 8710150101 071007 PDR ACRS PDR T-1616
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'PUBLIC'NOTICEiBY.THE'
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' UNITED' STATES NUCLEhR REGULATOR COMMISSION'S.
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'ADVISORYLCOMMITTEE ON RENCTOR. SAFEGUARDS 1
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- . WEDNESDAY,- OCTOBER 7,,19 8 7.;
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.Thecontents-oftlkissenographictranscript.of'
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the proceedings of the United. States Nuclear RegulatoryL
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. Commissi'o.n's A'dvisory Commitlee i,niReactor Safeguards (ACRS),
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. as..repor'ted!h'erein, is.an~uncorrE'. y cted record'of)the 8
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I discussions reco'rded at the' meeting. held on thebabovoida'tel 11 12 No ' member ' of; the' ACRS Stfaf f and 'no 'partici' pant' at -
j f 13 this meeting accepts any 'respons'ib.litiy for - errors or 14 -
inaccuracies of statement-or data (cont'ained'in thic
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ADVISORY.. COMMITTEE ~.ON ~ REACTOR : SAFEGUARDS.
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' SUBCOMMITTEE.: ON ' SAFETY PHILOSOPHY, TECHNOLOGY k[-}-
AND> CRITERIA;
(
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.In'the' Matter of:
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6 SAFETY PHILOSOPHY, TECHNOLOGY' )
AND CRITERIA.
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7-1717'H(Street,SN.W.
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- Wednesday' October 7, 1987 10 11 The above-entitled matter'came..on for hearing,.
-12L pursuant to notice,'at 6:00.p.m.
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13 ACRS SUBCOMMITTEE MEMBERS PRESENT:
.14 DR. WILLIAM KERR 15 Professor of Nuclear Engineering.
Director, Office of Energy Research 10
-University of Michigan..'
Ann Arbor, Michigan
.17
.DR. FORREST J. REMICK 18 Associate Vice-President for Research Professor of Nuclear Engineering 19 The. Pennsylvania State: University University Park, Pennsylvania 20 DR..CARLYLE-MICHELSON 21 Retired Principal Nuclear Engineer Tennessee Valley Authority 22 Knoxville,. Tennessee, and,
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Retired Director, OFFICE FOR' Analysis and 1
23 Evaluation of Operational Data q
U.
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24 washington, D.
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- ACRS SUBCOMMITTEE ' MEMBERS PRESENT- (CONTINUED) :'
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' DR. DAVID OKRENT.
1 Professor of Engineering-and Applied' Science 3
Department"of. Mechanical, Aerospace'and
. Nuclear Engineering k)s) 4 School.of Engineering;and;AppliediScience g
je University of California--
5 Los. Angeles, California 6-
. MR. DAVID.' A.-
WARD ;-
Research. Manager on Special.Assisnment 7;
E.IL du Pont de Nemours.&. Company,
-SavannahlRiver Laboratory'
'8 Aiken, South Carolina-1 T9 iMR.[ CHARLES.J./WYLIE Retired Chi'ef(Engineer 10 Electrical Division
~ Duke Power Company
. ~31 :
Charlotte,. North. Carolina
12
[
J13 I TACRS' COGNIZANT STAFF MEMBERS:
t14 J.:SAVIO "15, D. HOUSTON J
16' 17-NRC STAFF PRESENTERS:
18 SCOTT CROCKETT, Esq.
(OGC) and.
19' M. MALSCH, Esq.
(OGC).
20-R. W. HOUSTON (RES).
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'DR.' OKRENT:.The' meeting willLnow comeLto'o'rder.
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'This.is a. meeting of the Advisory Committee-on
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..a f4-Reactor Safeguards.Sub' Committee.on Safety; Philosophy, g.
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.Techno' logy"and Criteria.,
-O' I am' David,Okrent, Sub Committee Chairman.
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Other'ACRS: members in. attendance todayLare-
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8 lMr.;Michelson,fMr. Kerr, Mr. Ward,-Mr. Wylie.
.' g L.The' purpose ofthis meeting is to[ discuss $lans 10 for? incorporating the ACRS recommendations'..on'. safety goal-11 p licies implementation into Lthe. policy implementation p1'an
.12 and to briefIy' discuss'the legal definition of4 " minimum
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I 13 reg'uirements for adecuate-protection,"1as applied inlthe proposed Backfit, Rule.
34 15'
. Dean Houston and Rich Savio are'the cognizant ACRS staff members to this meeting.
16 The~ rules of participation in todaysimeeting have 37, been announced as part of the notice of this meeting' prev'i'o'usl y 18 published;in the Federal Register on September'22y 1987'at 39 43563.
20 A transcript of the meeting is being kept and will 21 22:
be made available as stated in the Federal Register noti'ce.
It is requested that each speaker' first identify hin :-
23 self or herself and speak with sufficient clarity and volume 20 s
that he or she can be readily heard.-
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comments from'the. subcommittee members'on the' proposed ~
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(No response)~
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'I think maybe-we might-just as well.st' art;right H
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out with-he'aring from OGC1concerning;the Ba'ckfit Rule.
i l You wanti to come up to the Ltable, please or 7
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.g whatever is convenient.
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9 MR. CROCKETT:.I'11,just-sit.right here~if that'sf 10' convenient.
DR.-OKRENT: 'That wil.L be fine.
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12; MR.-CROCKETT:
We are Steve Crockett and Marty
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!-l Malsch from OGC.
13 I guess the question is what do.the. lawyers think
.g, 15-a'dequate protection is.
Now, the phrase is not defined in the Atomic Energy Act.
I always thought the engineers and 10 the: scientists knew what it meant, but~I suppose that we 37 sh uld-be somewhat accountable here because we urged on the 18 19 court-in the' Union of Concerned Scientists Case an adoption.
20 of the two tiered approach in which any backfit that was L
21 carried out in order to secure adequate protection would not 22 be' subjected to'a cost benefit analysis, but any backfit q
23 which went beyond adequate protection would be subject to a
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. cost' benefit analysis.
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Now,.let's:begin then with theadecision.'since y-()s:
4 lthatisthe~.legalaction?whickhas. raised'thisnotionup'.into
>5 1high visibility.
6-According to the decision,: adequate. protection cer--
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-tainly is~not'zero risk and.it'certhinly'is'that' level:below
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- which cost is,notLa consideration. !I don'teknow how much help r:
8s that.is'.-
It may seem a rather unrealistic approach.. I suppose; 9-
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. if y u graf t ' increasing safety --against increasing cost co.. -
33 -
- sideration, it might look something'like a parabola'with the.
concave' side. opening upward.
There-doesn't seem to be any) 12:
(discontinuity along that curve..
Cost simply, looms ever-q 13 arger the more stringent the. safety requirement-you're; con-14-4 15 sidering.
16 I am afraid though that this two tiered approach i
17 ls probably the future.
The court was pretty firm in this decision and in the decision which came down about a weekLbe-18 I19 fore'our backfit case, a somewhat similar two tiered approach 20 was imposed on the EPA, where the key terma-were, "not ade-21
.quate protection," and b'eyond adequate-protection but " safety" l
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22 and " margin of safety".
And, in-the latter case by an 11 to
< 1 23 0 vote, quite unusual these days in the D.
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Court of Appeals 24 the Court came down in favor of that two tiered approach.
25 Now, however impractical, in theory, this approach j
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may;be, I'think there!is strong: indications that, in fact, af
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"the Agency has been-working.on some-such dist'inction for a-p 1
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. good long(time'.
'4, The. rule itself,.long-before I came to?OGC,.had h
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in.'it provision for certain undue risk exceptions.
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undue risk.- There was also a footnote exception, somewhat'
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9-undue risk.= To all appearances, the phrase,1" undue: risk,"'
10 lookedclike-it was being used as a synonym for the phrase 11 adequate protection and.it appeared to me that.the. drafters of 12 the rule understood'when-they were faced with undue risk and-13 when they weren't, that they knew how to make that simple'on -
14 off. decision.
15 There are other indications too that the Commission-16'.
-that various parts of the Commission seems to know what it 17 -
means 13y " adequate protection. "
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18 The Commission, for instance, itself has certain safety goals.which it thinks are not universally met, but 19 20-it n'one'the less thinks that the protection which implaces" is' adequate barring information which would reveal otherwise.
21 It sets'itself as a goal, no more TMI's, but we 22 7
clearly haven't reached'that yet,.so whatever " adequate pro-23 tection" means, it does not mean no more TMI's.
24 The staff apparently has some kind of notion.
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im-In-.looking at thab matrix, I took the bottom i
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.recent months.:.
(3' "line offitIto:be'somethin~g like,a definition.of inadequately
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- protection.
- That'is the risk.of core-melt greater than;1 in' e
J5 a:1,000 and neither one of the saf'ty. goals met, if I' recall n
c. the mat $rix.; LAnywhe're. about that; bottom-line,. apparently was L,f 7:
"a'dequate protection,~" and cost' could'.be taken into considera-tion'.
8
^..g' LI.have even seen attributed,to onef. member'of this.
subcommittee, the figure l' in.10,000per year--reactor year:
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r jy risk lo'f core melt and 1 in a million risk-of~significant'.
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_ ff site release.
That comes out to about a-1 in 4 chance-(. li 13 of a.- TAI :in :a population of 100 reactors operating to 35 14
. years.
That seems--I/ don't know whether that was being pro-l 15-
' posed as a safety goal.or a,' definition of " adequate protec-16 tion," but'it seems.to be,..in general, in the same neighbor-17 -
hood as these other estimations and figures that I pointed!
18 out.
Outside of th'se semi quantitative definitions of 19' e
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" adequate protection," I am afraid I,-as a lawyer, can't come
'21 up with any better definition of " adequate protection" than i
22 I could if you asked me what justice was--handed me the cases 23 of.the conmon law and asked me what justice was.
I think, 24 in response to that, I would say--the best I could say was, 25 it was the sum of the judgments arrived in particular cases--
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In'the. case;of " adequate.
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among:you might be able.to find-some thread of' consistency.
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stances, but:I'm-afraid it might>be like thinkingLthat.you' j
7; saw? canals on' Mars through'aDtelescopelon a windy: night, 8
I'm.sure I would put a whole lot of: faith:inLit.
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.In sum,.I think'that' phrase-which.youthave been'.
10 handedfby the Atomic Energy Act,'the phrase, " adequate pro--
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11 tection," is an invitation or maybe I should calliit a command
' 12, Lto1you as scientists and en'gineers.to ask as judges andito:
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- 13 work from circumstan'ce-to~ circumstance on a method;very much 14
'like the method in precedent.
- '15 There is room for you to change yourJminds, but 16 you would have to make some kind of justification of that chance which would make it look reasonably cons'istent withi 17 18-what had gone before.
You end up, not.with bright line' of1the court',
39 20 that seems guite consistentthere between " adequate".and:
"more than adequate,";you end up with kind of a; meandering 21 river, but I think that the change in the course of-those 22 23 judgments is stable enough to permit technically reasonble 24 and technically competent people to come to some kind of
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25 resolution in any particular case about what constitutes
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I guess'I probably don't guite' catch ~
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those--
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That's a. separate question.
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.MR. MALSCH: 'That's a separate question.
.10 MR. WARD:
Okay.
11
.MR. MALSCH:
I think the way-the Commission 12
. regulatory system would operate, in compliance with the 13.
regulations would, under almost any ordinary circumstance, 14 beLpressumed to also amount to adequate protection'of public 15 health and safety.
E ig But, it wouldn't necessarily follow that the two
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Conceivably the regulations could be asking'
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..non adequate protection backfit which the staff was imposing 20 to further minimize dange'r to public health and safety, once.
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.that_became part of the regulatory system, you could be in 22 compliance with the regulations and have, in theory, more thar t i
' adequate protection, but you would at least have that.
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Or concersely, you could have some-24 2
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.MR. MALSCH:.The-classic example of.that-would be
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and had to be taken into account.
9 DR. OKRENT:
.Let.me...give an example'that may be 10 able.toidraw~you out.
I'think 'it was the St.JLucie hearing, Til
.the. Board did not feel that the: situation with regard':to 12 Station Blackout,'provided. adequate protection, however, s
~13-the reactor met..the regulations, I believe.
j 14 So, I would say here was a case'where one branch.
15 of~the NRC itself found,what I.think a' lot of us know, that 16
.the regulations are not adequate and they,~in fact, impose 17
.on-the staff'some requirement to go back and look at the 18.
. situation.
i 19 Now,'do'I understand--these words,-it would seem
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I 20 to me when the staff took tha't look, they should not have considered cost since there had been a judgment that there j
21 was not. adequate protection by this' hearing board.
22 23 Am I missing something?
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Well, I think, in theory,that should 25-have been the case, although I think a distinction between l
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"considering costs," and " deciding adequate protection" that i
h we now see as a result of the court cases, it was considerably 2
3 less clear back in those days, but they did consider cost, in
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4 fact, in the resolution of the--the unresolved--faced the j
5 issue on Station Blackout, but it sounds like that would have 6
been a clear case where, not by the Commission adopting a new 7
rule, but by a finding of one of its own legal bodies that 8
the regulations were not adequate.
9 I assume that is similar to adopting a new rule, 10 correct me, if I'm wrong, MR. MALSCH:
Well, somewhat similar, except though 31 12 that, for example, in the case of Station Blackout, which was the issue in St. Lucie, the Commission is not bound by, even 13 it's own adjuditory decisions. It can revisit the question 14 in rule making and then cite again where to strike the 15 balance of adequate protection in relation to Station Black-16 out.
I suppose that's part of the rule making which is under 37 18 way.
It gets very difficult because, it's easy to say sor t 3g of glibly, that Station Blackout is an adequade protection 20 backfit, but then which fixes to fix Station Blackout are the 21 minimum necessary and which go a little step beyond that be-22 0
cause they're cost effective reduction in risk.
It's very 23 complicated to try and disentangle things and separate them 24 out neatly, as lawyers would like to have them done.
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That gap, in' fact,.is,relatedJin) a
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a'dequacy is in the ey'ejorethe beholder?
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Now, is the. beholder the expert in the;
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' reasonable beholding?.
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MR. CROCKETT:
You can'.t beia' lawyer, fright, in 1
A 17 reasonable beholding, and-know what the issues are.
18 MR. MALSCH: And the beholder can Indeavor to'be
'a little mor\\e specific about it b'y coming to grips with the
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21 That se,rt of gives content to it-and we're not running on a J
. completely clean slat'e here-22 We weren't even running.on a completely clean
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slate when we chose that particular legal theory to defend 24 the ba'ckfit rule.
That's one of the reasons why we chose it.
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DR. KERR:
One would expect, it would seem to me, N
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2 that a body, such as the hearing board, might look at a parti-3 cular situation and decide that protection was inadequate even though presumably the plant met the rules.
4 5
Another hearing board constituted with a different g-group of people might reach a different conclusion and that 7
would not be unexpected.
8 MR. CROCKETT:
Like to many district courts in the 9
federal system, it would be up to other parts of the agency 10 to--
DR. KERR:
But one would expect tremendous dif-ji ferences in viewpoints but they might be differences which one 12 lllh 13 might expect.
14 MR. MALSCH:
And ultimately both decisions would, I
15 maybe at different points in time, land on the Commission's 79 door step, which would be called upon to somehow reconcile it, 37 either by speaking in the latest case or by consigning the 18 19 matter to some rulemaking or policy making function.
20 DR. KERR:
No.
When one goes beyond the adequate 21 to improvement, again the process of deciding that more than 22 adequate should be enforced in cost benefit calculations
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should be indicated.
23 Where is it expected that that will be triggered?
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reviews on the part of Commission staff or' does that have 2
to be established?
3 MR. MALSCII:
I think the least likely source,
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4 frankly, would be hearing boards because I think the frame 5
work has been set up to do those kinds of things.
It's 6
principally in the Backfit Rule which is principally addressed 7
to the staff and the Commission and not to the hearing board, g
DR. KERR:
No, but what I am trying to get at is:
9 When would it be decided and by whom that a backfit should be considered in those cases in which it is determined that 1
10 ji adequate protection exists but more than adequate protection 12 is desirable which I interpret this--I mean, as I understand lllh 13 it, interpretation.
When, has adequate protection, but for y
various reasons, or whatever, "more than adeguate protection 15 is desirable provided it meets the cost benefit criteria.
16 Ilow is that--is the beginning of that consideration 17 likely to be triggered?
Who is likely to look and say, this 18 plant really needs more than adequate protection or is that yet 19 to be determined?
20 MR. MALSCII:
Well, I'm not sure it's completely yet 21 to be determined but, in practical effect, it resides with the 22 staff, looking at license applications and looking at generic
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It may be done generically 3
or later, so it's normally a function of the staff's review
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4 process.
5 DR. KERR:
So it would, perhaps, be most likely to 6
occur in a situation in which, say an older plant has met the 7
existing regulations that were in effect when it was licensed, a
but a later regulation which d3S not--which had immediate 9
effect in this, but didn't got back, would lead reasonable 10 people to conclude that, yes, that's why it ought to be back-11 fit, even though it was adequate when it was built, but it 12 wouldn't have been adequate today had--is that in a category
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13 of one that would not have to meet cost benefit criteria or GJ would have'to meet cost benefit criteria?
j 14 15 MR. MALSCH:
I would say that it would, unless l
16 you're prepared to re-visit the question of whether there was 17 adequate protection and assuming the regulation was' drafted 18 so as not to apply or grandfather the old one.
DR. KERR:
Adequate not as attached to it on a 39 calendar basis.
It was adequate in that in 1975, but at the 20 1
21 same plant, had it been built today, it would not have been i
29 adequate and that--
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MR. CROCKETT:
There's a tendency for that river to 23 meander in certain directions.
Part of that is the state of 24 25 the engineering argument, changing direction and so forth.
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Given that,~under the existing circum-5 stances, if the staff decided that this older plant should be 6
improved, is that a backfit under the new interpretation or 7
is it not a backfit?
8 MR. MALSCH:
I.would say it's a backfit.
9 DR. KERR:
It is a backfit and yes, it would have tc.
meet the cost benefits criteria.
10 11 So, in order to bring a then adequate up to a now 12 adequate, one must do more than adequate, sort of?
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13 MR. MALSCH:
The emphasis is on more than 14 adequate.
I mean, as I say, it gets to be kind of a--you get 15 yourself into a logical trap.
I mean, if one were to say, 16 that ones concepts of what is adequate have evolved, then we're launched right into the exception about not consider-17 gg ing costs to bring plans up to a level of adequate protection.
So it depends strongly on how you state the question.
39 DR. REMICK:
Let me try with another example, if I 20 could.
I think I understand what you're saying, but let's 21 22 take for example, filtered vents.
Now presuming we found that plants are safe enough 23 without.
They meet the regulations without filtered vents and (V~)
24 25 apparently there's adequate protection.
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8-MR..MALSCH:
That'would be:a nice wayjtodo'it.
9.
.I' don't think it would be.the--
1 10
'DR. REMICK:- Too' logical?'
11
-MR. CORCKETT:
Might..be able to do it by reinterpre-i 12 tation-of the generally stated rule.
(,
13'
.DR.
REMICK:
Reinterpretation of what?
Reint'rpretation--if._the rule MR. CROCKETT:.
e 14 15 establishing:the original standard.was stated generally, it 16 might'be subject to reinterpretation.
l 37 MR. WARD:
You-might saylthat given this emphasis
~~
L on research, what we know today, that.we didn't know 20 years 18 t
39 ago, is that we really o'ught'to have filtered vents and then-1 20 it would be just bringing it up to'the applicable standard?
MR. MALSCH:
That sounds a little more like risk
.21 assessment.
22 Let 's say that---
An interesting thing that would 23 be--let's suppose there's also an exception-in the Backfit Ru:.e 24 for backfits needed to bring a plant into compliance with the 25 1
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there's no. cost benefit analysis entailed when you need.to.
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situation'.
Facts develop such that a prior.' interpretation 15 is simply not tenable,
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16i MR. WARD:
Okay; And that's where it really wasn't.-
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17 in, compliance.withCthe': regulations.
A 18 MR. MALSCH:
You' looked back and said, oh my gosh, i
19
.how could we possibly have said that or we can't possibly say.
20
.that now knowing now what we know now.
21 The example was that a rule which required actual 22 operating experience and the staff had been interpreting that 23 to say that experience on the simulator was sufficient and 24 that was fine, except it was hard to defend saying that 25 experience in a simulator was within the language of the rule, j
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3 DR..OKRENT:
Does'the staff ~need,to-~dolanything<
!4' to:make.more clear'what.it thinks that' adequate protection 5
or just as11ssues'comelup,-arrive ~at a judgment that'it's 6
notiadequate orgit is-' adequate butishould'be considered $
7 under. source, benefits and giving some plausibility arguments; 8.'
with-no guidelines--no' Commission guidelines, no: staff.
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i 10 MR.' MAL'SCH:
In the best world, or maybe even'in-a; 11:
~better.world, there.,would be some general guidance' promulgated 12
- by the Commission,.but I can't?say it's-required..
q Uh 13' The Commission is free to develop.a concept'onia.cas e:
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16 way of safetyLgoals, it's still'not'exactlyfclear exactly.
q 17 how they're going _to be linked to protection because
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19 developed. common.to the pertinent data.
20 DR. OKRENT:
But it would appear that.those 21 goals are intended to be something beyond adequate protec-l
~2 tion.
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23 MR. MALSCH:
Yes.
As long as7you.say you shall
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25 under which you. consider cross, then you can no longer say l
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'a consideration.. Meeting the' goals and-saying, ah, that's
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-where/ adequate protection ~must be,'by" logical inference'.
9-
.The drafters of the plan may'not have.been thinking' 10 so. clearly and'not-have-had the'two stage approachLin mind 11
- when they.'draftedLthe implementation" plan.
.12 DR.OKRENT: I ought to note ~that;to my knowledge-f 13' that" matrix is only a pr'oposed matrix.
14 MR. MALSCH: That's right.
15 MR. CROCKETT:
I don't mean..to imply that I was' t
1G' taking it as the. staff's final judgment.
It shows an71n-r 4
.clination, on.the part--of'the staff.to peg adequateLprotec-
- 17 4 "
18 tion at a certain level, either knowingly or. unknowingly.
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.I 19 DR. OKRENT:
I must say I hope that that doesn't 20 remain the general definition of " adequate protection."
It
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21 would be unfortunate.
22 MR. CROCKETT:
I hope so too, even in comparison I
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But I don.'t think the' people who are Lg-3 working'on that plan.had clearly in' mind,,as I suspect;they
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- between now considering economic costs, setting levels of 33-adequate. protection and operati'ng.above it, so I'm not sure' 12
- if theylwere to go'backJand redo.it, they would come up with 33' the same numbers.
I don't know.
14' MR. CROCKETT:- I wanted to add one other thing.
I'm
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- not sure that the profession is in the position to nail 16:
adequate protection down any more securely.
17.
That means, I think, that in the interim, until l
18' PRA's-are perfected or whatever,;that day will never come.
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In the. interim, the best thing the staff can do is to be very 20.
clear in every individual :ase whether it thinks this is a 21;
- case of adequate protection or not and then gradually a body i
22
'of precedents that we can deal with will collect.
I'm not-LO-23 sure there's any other alternative, really.
24 MR. MALSCll:
~ think we have been working with 4
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4 iDN. REMICK:- !Maybeji.t wasimentioned earlier!lb'efore' 3
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Is adequate;. protection' synonymous.witho'utfundue; L5' risk??
MR.'MALSCH:
- Yes~. That has,been' presumed.;
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Okay.
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~8 MR.:MALSCH:
'Actually ifTit goes by the statute, 9
the safety standard is stated.about: 4 or 5.dif ferent wa'ys.
-No-one has ever suggested seriously that they mean different 10 11.-
things.
12 DR. OKRENT:- 'Any other questions by the staff?
13 (No response) 4 DR'. OKREN: - Thank'you very much..
t 14 15 Okay, I guess it's now time to hear from the staff on their thoughts concerning implementation of the safety, is 17 goal. poli ~y.
MR. HOUSTON:
Ifdidn't convert these into overhead 18 l
slides, so if you don't mind, I'll sit down.
39 l
20
. Okay, sure.
DR. OKRENT:
MR. HOUSTON:
Some of your had an opportunity to i
- 21
-1 look at the set of handouts we sent to you.
There have been.
1 22 o
a few e'ditorial changes on at least one page which has a major 23 change in.it, so it has been updated and it is being passed
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24 25 out right now.
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it's-. unusual, but' thank you.'
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It's moresthan I would;normally put y
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~on a view ~ graph making a presentation.
-6 I usually.like'to make,aivu graph.because.of-the' 7
buzz' lines'that promote-conversation..
8 I am certainly: delighted that-we've found'an-
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opportunity to_ meet,with you:this: evening.
I"believe that it came about by request.
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10 travel very recently and I appreciate the opportunity'..to
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. spend'the nextLhour.or so with you'on this subject.
12 13
- The remarks that'I will havecto make, I want.to make jg4
- clear at the outset, are properly titled,_"Considerat' ions-for Revisions in the Safety GoalLImplementation Plan."
15
~There has:been, proposed, as you're' aware and-1 16
, reference has been made to it the'past few minutes,.an 37 implementation plan which was sent to the Commission back in 18-January of this year.
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20 21
- purposes of our talk tonight, I am talking about the considerz tions in applying recommendations and suggestions in the May 5:
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It is in the context of that' plan.
23 The scope of the discussion largely follows the
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L5 I'think the staff,is aware,.,however, that--there are,1 16 Lperhaps some' perceived problems with.the Safety GoallPolicyl-i,
.7 Statement andlit is not. entirely' impossible'that the outcome of our'ourcefforts could resultiin some recommendations to
' 8-9 the Commission _that might resultfin' changes.to that. statement.
10.
That's not the immediate objective,.but.that could happen.
11 So the emphasis I would like to put on is-inter-12 action!with you pursuant'to-recommendations-given to us"by
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13f the Chairman through our Staff RequirementLOffice.
14
.The'ACRS recommended what is basically a 3 element 15 plan.
TheEuse of~the safety _ goals suggests the adequacy of
'16 regulation-with an admonition against:using it to--using; 17 safety goals as a basis or the sole basis for making regula-l 18 tory judgments on plants.
19 The second element was the proposed hierarchical 20 structure and the third, continuation of a programr of. risk 21 estimates with specific palnts referred to generally as a 22 sampling program.
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24 about the use of safety goals and quantitative objectives 25 which I will probably interchangeably use the term, "surrogater:,"
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6 The principal'. focus;of.anrim'plementation plan.for-
'7 Lsafety goals'in really.on the use'of' risk-assessment methods;
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8 and techniquesL That is probablistic risk analysis o'r risk'
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.13
.I see the same thing.here.
.14 When'that.information}isavailable, it may'.come 15 as Information-developed by aniapplicant'or by a vender, it imay;.come:from information".that.is'done by the staff.'or by 16:
17 contractors for the' staff-oriwhatever source.
When Risk 18 Assessment information islavailable, it gives rise to'the 19 potential use of safety goal-tartets'.
20 The principle emphasis though that we would wish'to 21 make. in revised implementation plan is that safety significant e-22 is really much more in the process of doing a risk assessment 4.O7 than it is in the bottom line of numerical results.
j 23 24 MR. WARD:
Can I comment-on that?
l 25 MR. HOUSTON:
Sure.
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MR. WARD:
You know, it certainly has become the 2
popular thing to say the last few years, and with some o
3 justification, people being killed, and they have become 4
alarmed about too much emphasis on the bottom line of the 5
PRA calculations, but I think the bottom line is very impor-i 6
tant and it's what really is unique about the PRA as opposed 7
to other discipline method of analysis, failures, modes and 8
effects analysis and other things and it sort of really 9
exerts its own discipline on the whole process and influences 10 the process.
ji People decide what to leave out and what to look 12 at and again, in the process, based on testiments about the 13 bottom line, so I hate to see the numerical results of the 14 PRA down played too much because--
15 MR. HOUSTON:
They can't be eliminated.
I didn't 16 mean to imply that.
I think they may be useful for compari-17 sons in asking them the question, you know, the comparison 1g gives you some sort of a feel for the goodness or in the bad-ness of things and then you ask the auestion, why?
39 20 If you're reviewing the PPA, you go back into it and 21 really look into that particular question.
I think, on the 22 other hand though, that if one puts too much emphasis, or r
attaches too much significance to the bottom line, then the 23 syndrome which you mentioned, I think, is exactly what prob-ID 24 U
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.doLnot: thoroughly recognize the compl' exit'ies of the methodoloc y.
8
- In the Commission Pol' icy Statement, the safety.
9 goals are--this is part of a quotation:."The level of; risks
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11 p1' ants..." andiI note that the-staff would ortshould expect 12
'that licensees'and~ future applicants might use targets ex--
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I think it is a tool that i i 19
.should be used by the industry and can be used also in the I
-20 regulatory process.
I think it has application in both j
21 areas.
'22 I might recall that one of the statements in the 23 HR letter was to the effect that management, engineers and operations personnel really should become intimately involved
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think this is a misdirection.
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2 Whether the NRC staff or anybody else looks at a 3
PRA may not be as important as a utility doing an excellent is 4
job of actually doing its own risk assessment, it's own 5
evaluation of the safety of the plant by that kind of a 6
methodology.
7 As an aside here and it has occurred to me and in 8
thinking about the remarks I might make tonight, the kind of~
9 thing that one might be considered in an implementation plan 10 also would deals with such things as a starting point if, 11 indeed, it can be perceived as a starting point, that 12 personnel might shift technical advisors, for example, in a
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la plant.
Perhaps you would be qualified, in a sense, as a x-14 PRAM or something of that nature.
15 If they are called upon to deal with the unexpected-16 to the extent that they are called upon.to deal with un-17 expected events and they should be participants in the pro-18 cess.
19 The staff use in regulatory activities should com-20 piement but not substitute for deterministic engineering 21 judgment on the adequacy of safety margins in current regula-22 tory practices.
-s' b 23 You would expect with the hierarchy surrogates,
~~h 24 if we're able to develop them to an acceptable way, should (O
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- 14-Earlier you-quoted from the commission Policy Statement.
15 These statements you're making now are those.of'the curren$.
16 staff thinking?
How should I interpret these'last coupid'of s
17 bullets?
18 MR. HOUSTON:
Well, it's a little hard for me to q
19:
characterize this.
I hate to use the word, " staff" here and 20
..I must say that this is.what I am talking about tonight, a lot.
21 of the things I am talking about may sound like their staff 22 positions, but I am not intending to mean that.
This has.
-Q 23 not gone through the entire process of concurrence, if you 24
. will, and does not have the stamp of approval of the Execu-25 tive Director of Operations.
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DR. REMICK:
Is the staff thinking about it now a
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that--
3_
MR. HOUSTON:
That 'part of the. staff is charged y
( -)
4 with the responsibility of revisions.in the plan.
This tends 5
tp be some of the thinking--the kind of thinking that we're-6 now considering and talking about.
7 In spirt of the fact that they're not standard 8
requirements, quantitative PRA results may be compared with 9
surrogate targets.
The degree of confidence in what that 10 comparison means, is important.
We certainly agree with 11 the recommendations, I think, generally, within the staff, 12 though there might be some except ions to that, would agree
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13 that it should not be used for narrowly differentiated t-14 decisions.
15 Now, for currently licensed plant', including the 16 few that are still under construction, the safety goal surrogate sh'uld be a useful. tool for evaluating results of o
17 18 the individual plant evaluation program for the IPE's.
q 19 For future plants, the severe access policy state-20 ment incorporates expectation of a full PRA.
They're build-21 ing a full scope PRA.
And onc view is that the staff in reviewing such a 22
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I don't1.know though'what that.really-i4'
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.' 5 MR.;HOUSTONi Let me give you;an example.
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'mit the PRA reflecting, the' Systiem 80 plus..
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Now', to me thatis, sort of a logical and construc-17'
'tive way to use the PRA.
I can't assert that Westinghouse 18 or GE are doing the same thing.'
That's the kind of thing 19 that I mean.
j 20 We don't have to agree with their results, but we i
21 ought to be able to see,'in that kind of process, that I 22 described that they have actually used it in a constructive O
23 fashion and have at least moved closer to desirable targets 24 if not, in fact, reached them.
25 DR. OKRENT:
Suppose in the staff's opinion, they Acme Reporting Company 3
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MR. HOUSTON:
Let me see'if I can clarify.-
9
- I'm using.the word," target," in-the sense-thatLone 10 -
'doesn'.t always.hig.the. bulls eye'or target.
11 DR.'KERR:
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.12
'you're reaching for,.you~ don'.t quite.get there, but you reach
' 13 :
toward it..
14 MR;' HOUSTON:
Let me use this.
A-few years ago.I 15
. met with'some of youfin conjunction with-the still.present.
to subject of~the containment performances and one of you,JI 17 think'.it might have been Dr. Kerr, asked the question: "What 18 would you like'it;to be?"
Not try this and see'what the 39 impact-will be, but what would you'like it'to be and that 20 is sort of how Ilsee-these targets and I.think it's the same-t 21.
thing.-
To go back-to your question, I think.the thing that
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I would find inexcusable, on'the part of the staff, is'to 23 I
cite as.a reason for proposing a required applicant to do 24 25 something is the fact that he doesn't meet those targets.
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We have reviewed 5
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better.
7 It depends on how far away and whose target it is.
8 It depends on how creative the staff review it.
Your judgment 9
has got to enter into it, but it should avoid crawling 10 back and there will be a tendency on the part of staff people 11 to do this say, you know, you don'*. meet the target, there-12 fore--and you got to meet the target.
(
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13 DR. OKRENT:
And as to this issue of meeting the q,-
14 target.
15 MR. HOUSTON:
Well, that's when I said, it depends 10 on the degree of confidence that you have in it and if 17 you try to quanitfy that, it seems to me you're'back in 18 the same ball park.
19 Maybe one can say, for example, and people sometimes i s the bottom line numbers in a 20 do say, that reliability 21 PRA, perhaps they're no better than an order of magnitude.
22 Clearly if a review shows that they are two orders
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'doesn't.have an approach that Tus could have confidencefin'new 8
plans,:some degree of confidence that they'had met it.
9 It's'reallys that--if there had been'an order-of 10 magnitude ofimeeting-it,fthat's.almost the way it.comes out.-
o 11' MR. HOUSTON:
No,~no, no, that isn't what'I meant-e 12
.to;say. LI didn't mean to imply that if it wasiin'an order of 13 magnitude, it's.okay and that's what I meantJwhen I.said, 14.
if you.say that kind of' thing, you're:right.back where'you t
15 started from,.of the bottom line syndrome'and this movesEit 16
'an. order of magnitude away.-
y, l17
'I don't ;think you want to cuantify that judgment-i 18 question because the minute.you do, it seems to me it's the 1
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10 same thing actually as hardening the target saying this is 20 something that must be met.
21 DR. OKRENT:
Well,-if I can try to interpret the 22 ACRF letter on implementation.
That's a dangerous thing to 23 ~
do,.of. course, but it's my last meeting, so they can fire me.
I 24 It seems like they were saying you will use PRA
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Let's say you evaluated this station and f
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10 DR. OKRENT: -I'm.notfsaying that that1 would be the 11' conclusion, butLI think this is my understands'ng of how,Lin 12>
effect, procurement apply. PRA and.the'--
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G MR. WARD:
Wait, you said something different there.
7 You just said it could be a point of departure for assessing 8
the need for changes in other plants.
9 Here you say for assessing the need for changes 10 in regulatory requirements.
it MR. HOUSTON:
What I meant there was that if you 12 take Peach Bottom, 1150 treatment as a point of reference or llh 13 a point of departure, you might find that there are 8 other 14 BWR Mark l's that have some unique features different from 15 that in Peach Bottom which warrants a requirement which would 16 be generic for those 8.
That's the kind of thing that I was i7 referring to.
18 MR. WARD:
You see, what we want you to do is then go a step further and figure out what is there'in the regula-39 tions regarding these plants--
20 MR. HOUSTON:
I understand that.
21 22 MR. WARD: --that' permitted these two classes.
~~
i MR. HOUSTON:
I understand that.
23 MR. WARD:
All right.
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24
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2 MR : WARD:
Okay.
I have another--well, maybe this 3
is the same question, but' with regardjto tiie last item on that
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page.
5 Well, let me bring it up when you get to the'next--
6 where you're going to talk about the scope.
Go ah'ead.
7 MR. MOUSTON:
Okay.
Going through it sort of tier 8
by tier now with some comments.
The qualitative statement 9
was given, of course, with the policy statement.
I think it 10 is important to point out that they are articulated as 11 General Orders for' Nuclear Power Plant Operations and not 12 necessarily for each plant.
There is no direct use or appli-
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la cation that I conceive of as to qualitative safety.
14 They're summarized as 1-a and 1-b, one dealing with 15 risk of life and health of individuals in proximity-of the 16' plants and the other the comparability to viable competing 17 technologies.
18 I made the statement here, current applicable regu-39 lations, that is part of.the guidelines in Part 100 which 20 deals with radiation exposure of individual accidents off 21 site which is, in a sense, compatible with this.
22 All I mean by that is that the 25 rem exposable
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only with fatal'. ~Sosthere!is'an1 inconsistency there with 7.
regard to that.;
8 With respect to what'is sometimes. referred'toas the 9.
" front'sociatal risk,ea qualitative safety risk.
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13 think-'it's~any'more difficult than doing risk sutdies on 14 nuclear. power plants..
15-Sometime in the future, I thinkfwe ought to gohback-u v e 16 to this-question, if this concept is retained.
.I would hope.
17
-that in 5 or 10 years.one might actually need to come to some 18-conclusion as to the relevant risk involved between the coal 19 and the fossil plants.
20 MR. WARD:
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That may be.
I'm not proposing 23 24 anything in that regard.
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Have you got those documented so.mehow?
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How you translated those two numbern.
MR. HOUSTON:
It's on Page 8, 23 24 MR. WARD:
Okay.
~ 25 MR.. HOUSTON:
You'll find it in there.
What I think i
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Why not?
4 MR. HOUSTON:
All they need is Level 1, Level 2.
5 To look at the safety of their plan.
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You mean in a severe accident--the IPE I"'
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Partly because the IPE would only re-
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11 MR. WARD:
But otherwise I mean why wouldn't a P ant conscientious--
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Well, maybe I shouldn't make that v-g4 statement.
I can imagine that many of them are'rather skit-15 tish.about what the results might be.
16 MR. WARD:
Is the Safety Goal Policy or.is some-17 thing the staff is doing kind of counterproductive then in 3g the sense that it's discouraging licensees from doing these analyses?
39 MR. HOUSTON:
I didn't mean to imply that.
What I 20 21 meant is the present circumstances are that they are not re-quired to and it's not clear to me that they would neces-on sarily be motivated on their own to do the full Level 3.
23 They may if they are curious to see how they stack up.
I'm 24 guessing that many would not choose to do that.
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Probably.
16 DR _. REMICK:.. I think that was addressed in 0880.
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.mately met" it implies a little'. softness in there and I think there's a margin which might be needed to' support that 39 conclusion regarding the cancer fatality objective.and per-20 21 haps could be quantified in some sense, and I think that's i
something that the staff may wish to undertake.
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It really should be in 23 1
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"Further surrogates for the cancer fata-24 lity risks, quantitative health objective, are really not 25 l
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2 But it still may be a viable way to use, a viable thing to 3
use,-and it's not at this point in. time discounted.
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And we turn to page 9.
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reference to'a dose, an acute dose specifically to an indi-8 vidual, which might be useful in order to gain public under-1 l
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I think a lot of people have become accustomed.
12 in the last twenty to thirty years of the term " dose" and
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" dose" as the point of. reference in defining "large release."
15 Now, the statement, the number one statement here, 10 may be an arguable statement.
But in principle, the equiva-17 lence of a large release with the early fatality goal of 5 times 10-7 would be achieved if it were defined in terms of 18 19 the 50th percentile or mean lethal dose or medium lethal 20 dose risk of fatality.
Simply that given 10-6 release and 21 if that has a fifty-fifty chance of producing a dose, a
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then it would meet the 5 times 10-7 target.
That dose, of 23 24 course, is somewhere around 450 to 500 REM, expressed as a
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~says--that'sLthe sort of' thing we suggest shouldn't be.done 13-
'to introduce for some reason an additional level'of conser-14 vatism in translating into another tier.
You are suggesting 15 that the conservatism which you add in going from one' tier IG to another should be just enough to accommodate the uncer-17' tainty introduced by the simplification in going from one 18 tier to another.
But not' purposely to make-the whole goal 19 more conservative.
20 MR. HOUSTON:
Well, that.was part of the question I
21 I know in our minds as to just how the word " consistency" 22 might be interpreted and I think you just shed some light on AtJ l
23 that.
I guess what I'm presenting here, what I'm' talking 24 about here is simply a line of reasoning which may or may not 25 comport with ACRS recommendations.
I
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'l Let me finish.
We can come back to this so'I get
(_)
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of release.
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4 DR. OKRENT:
Excuse me.
If I can make a comment 5
now.
I made one back in the. letter.
It seems to me the 6
ACRs, in making this recommendation, doesn't allow for gaps 7
in the methodology or the data used in the predictions'.
Or 8
how to handle thellarge uncertainties.
So it's really, in 9
my own ming, difficult to think of consistency when one has 10 that kind of a situation.
And I don't-think the ACRS pro-11 vided a road" map.
It's.a hard thing to do.
.So I'm not 12 faulting.
Nevertheless, one has to wonder just what consis-
. (g) 13 tency means when you don't really have a handle on either of
~
/
14 the things that you are trying to make consistent.
I'll 15 leave it at that.
16 MR. HOUSTON:
I think any argument--again, if you 17 look at it, if you start down the path of looking at the 18 potential advantage of using a reference dose as some sort 19 of a criterion to get at a definition of a large release 20 that it could be viewed as an element of conservatism for 21 the precise reason that you mentioned, that it's beginning 22 to deal with the uncertainties.
How well you can quantify
,-d 23 that is something else again.
I think in the final analysis,
(~S 24 if this path were elected, it simply becomes a judgement O
25 matter as what seems to be general consensus, that this is a l
Acme Reporting Company 12028 6284888
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~' reasonable thing-to do and.a useful thing to do.
And I think ps
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3 What'I've indicated on page 10 is sort of a simpli-(~T '
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, reference to a dose to an individual at some distance from 6
point of release by basically an equation or equations.that 7
are in some sense are familiar.-
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. numerically'will be a fraction, some number less than one.
10
~Andfis a mechanism whereby one can define a release as an 11 equivalent amount, for example, 131 but calculated lin terms 12 of the sum total of release of individual radionucline compo-(
13
-nents and their respective dose conversion factors.
And on 14,
each side of the equation, each can be related to a specific 15 dose to a receptor at some point.
For example, at the 10 average distance, say, from one mile from a site boundary 17 or something of tnat nature, that number could be taken as a 18 fixed number, and it might be calculated, for example, on 19 the basis that it would be appropriate to consider something 20 like the average meteorology of sites across the country.
21 I think that the information that we have on meteorology at 22 different sites tends to show that the average, if one thinks, 3
J 23 for example, chi ovar Q, is not very much dif ferent at sites
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Although the variation of the extremes V
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Yes.
14
.MR.
REMICK:
Now, you are talking about acute
. 15 dose to-an individual within!one mile.
16 l MR. HOUSTON:
An. average individual.
That, of
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In the sense.that the uncertainties l
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I guess I don't see how you can pick
- 22 the average individe;.l.
How you do it from this standpoint.
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Add them up and divide by
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You see this'in the same manner as--
8 MR. HOUSTON:
Yes.
I intended that to be consis-i 9
tent.
10 MR. REMICK:
Okay.
11 MR. HOUSTON:
If one were to then, for example, 12 select by this process a release defined in terms of I-131(Eq; (n/
13 for example, it could be calculated by a methodology just i
_,/
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16 function and then come back to the equation here and for any 17 future application against this goal, one can take the re-8 sults of a Level II PRA in terms of all the individual radio-1 19 nuclides and perform this summation and calculate a number 20 which is the I-131(Eq) and compare it with that number.
21 Now, having said that, it must also be obvious 22 that all you need to do is since you know what this fraction V
23 was, which is a constant by definition, you compare it with
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But the point is it can still be defined in terms 25 of release and really you do that through the mechanism of i
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simply deciding that you are going to hold that'F constant
(_)
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'for this purpose, for the use of this surrogate.
That.may-3 be troublesome in some-minds..One would have to think acaut
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.the meaning of that term.
5 I alluded a little while ago to another possible 6
alternative which we've not really thought-about in any 7
serious sense.
But I mentioned earlier that we hadn't really 8
considered a surrogate to the latent cancer fatality quanti-9 tative health objective.
Now, in this case, if you take 10 10-6 as the-probability, you can't do it.
But another possi-1 11 bility is increase that by an order of magnitude to 10-5 and 12 thenLthere's a chance that you could derive a surrogate and
,5 l\\s) 13 define a large release which is consistent with the latent 14 cancer fatality objective.
I'm not saying'we should do it.
15 I'm just saying that one could do that. But that-is changing.
16 the guideline, the performance guideline, that was given.
17
.In any event, it seems to me that the staff has 18 to come to grips with this question of how to define large 19 release or come to the conclusion that you can't do it in 20 any satisfactory way.
But we'd like to because it also 21 comes up in the next tier logically.
22 Turning to page 11, my headline statement is,
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Whereas anything we've talked about 25 before really sort of avoids the concept of defense in depth.
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It seems to me-that's sort of an I
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But you probably wouldn't
'17 want~to go any higher than that.
18 MR. REMICK:
I. agree.
19 MR. HOUSTON:
If you went any higher than that, 20 you exceed-the number.
21 MR. REMICK:
I'm not sure that.you should go lower 22 either.
if3 ;
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'3 MR. HOUSTON:
Well, that's to me a judgement 2
24 que'stion.
l-25 MR. WARD:
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The, Safety) d d
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When you go'down L8 this'tieh, and jeople'look-at'it and say, " Gee,,what that n
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11
,1--
12
.MR.' HOUSTON:
And I'm not sure that will sell.
13.
DR. KERR:
There is a difference--
14 MR._ WARD:
It's'already sold.
15 DR. KERR:
There is a difference between saying-y.
'16 that it's okay-for somebody to die and saying that you are 17 not going permi't more.~than 10-7 risk of somebody to. die.
18 There's a difference.
19
'MR.
HOUSTON:
There's a difference, that's right.
20 MR. REMICK:
But all they are doing is defining 21 what they mean by dying.
You are saying 400 REM is weeping Lq 22 dying and'there's some conversatism in that.
23 MR. HOUSTON:
What I'm hearing then is that--and I b
24 think I understood this, although this clarifies it, that what t.J 25 you really meant is, you know, why not?
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Why do-you think EPRIIchose aLgoal
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Tl$ey.
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They are7 allowed tojdemonstrate.
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By-ihes. r methods of demonstrat2.ng.
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Why[not exceed the goal--
= 15 MR. HOUSTON:
Pardon?
i 16 MR. REMICK:
Why not exceed the goal if you can?
(
17 And the question of-uncertainty become moot.
18 MR. HOUSTON: Well, anyway, to proceed.
One point ID I would make here is that the ACRS letter recommended an 20 operational performance objective.
And I think we all recog-21
.nize such an objective is not quantifiable, certainly at.the 22 present time, and in probabilistic terms it's not something 23 that's really--the state-of-the-art of PRA is not such as to 24 admit to a lot of the factors that are currently thought to 1
i 25 be'or considered to be important in--
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W e l l,' n o w D a v e ' w a s." i n t e r p r e t i n g s t h e :
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i ACRS lletterf earlier iso I: want" to interpret '.itiat [this; point.
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I understand'that.
And that'sithe-
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much detail as1I'm presenting here,-and.he seemed to'be con-ys e'
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"15 lexcellenceLin performance as a major goal'of the Agency 11GI particularly with the. reorganization, and-he didn't want to 1
17J
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- Now, L.
'18.
that's what I'm saying here.
But I would prefer to make the
' argument that at this time it doesn't belong here in hier-19
'20-archy because PRA can't deal with it.
g 21 DR. KERR:
To-say excellence is a major goal of
- e i
22 the Agency can mean excellence ir the Agency as far as I
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23 Lknow.
24 MR. HOUSTON:
It meant excellence in operational 25
_ performance.
That should have been in it.
Acme Reporting Company GO2a 6284888
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And I think that's asking too much.
l 'O 2
MR. HOUSTON:
Excellence in operational performance 3
is what that meant to say.
4 MR. WARD:
You know, I am not surprised that you 5
are saying what you.said.
I guess I'm a little disappointed.
6 DR. KERR:
Don't give up.
We are no't exempt--
7 MR. WARD:
I don't know how hard'you" worked at it.
8 You know, I don'.t know how to do it.
I mean there's a real D
problem here with talking about safety goal or talking about 10 a probabilistic risk analysis as a find to an operating 11 plant as opposed to a design of a plant.
If you don't some-12 how deal with this question, and that's why we put it in the 13 letter.
Maybe you need all " bottom lines" to'have to have an 1
14 asterisk on them.
Like Roger Maris' sixty-one home runs or 15 something.
But it's not a complete statement of risk, and 16 I know without some consideration of this factor--
17 MR. HOUSTON:
Well, it's not a question of whether.
18 It's a question of where.
And I think certainly what your 19 letter said, because of the way you perceive--you would like 20 to see or are recommending that the safety goals and the 21 hierarchy be used--if I may paraphrase--to answer questions 22 regarding the adequacy of regulations and regulatory practi-23 ces.
You see this as a vital part of it.
l 24 DR. KERR:
I believe that the staff had agreed 25 that they were going to try to include seismic events in the l
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Well, I'11 makeJa. statement'about.
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Is it..your?viewJthat thel uncertainty e
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Tit has to be'one heck of a lot more complete than the be-16.
.havioral. sciences.
They are associated.with performance..
17 DR. KERR:
What would you say.about the risk l
18, associated with operational performance as associated with-
~
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'the risk from seismic events?
1 20 MR. HOUSTON:
The risk--if I'may qualify the 21 question in terms of the present plants that are out there, j
(
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23 of' performance are undoubtedly far greater than they are for 24 seismic risk.
Far greater.
25 DR. KERR:
I've made my point.
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I..just:: don't buyfwhat<is':being sug-
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If we' judge the management.and. operation;
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And if they 17 are poor performers, I'll set them back a factor of 100'on 18 what comes out of the PRA.
And I think that by setting them 19 back a' factor of 100, I'll be underestimating empirical ex-
-20 perience.
21
.DR.
KERR:
I'll throw one out you might consider.
22 -
2.6432 or better or no more than 1.3 in any category.
q.
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You now, there are various tools i
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That's one of them.
Senior managers 1
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s MR. bOUSTONi How'do you" quantify a sleeping opera-
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What is your estimate of the risk associated with - the opera-i
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I thought that up in five minutes, so it's 7
21
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.p 22 MR. HOUSTON:
That point is well taken.
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I Just gave you an expert opinion j
U 24 along the lines you are suggesting.
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Yeah.
Well--
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When we-said in the letter that we recop J;
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MR. HOUSTONt Well, I guess I shouldn't really at 5
.this point in time indicate any prognosis.as to how--whether 6
and/or how it may appear.
7 DR. KERR:
We're from the government and we're here 8
to help you.
9 MR. HOUSTON:
I understand.
'I'-ve heard that before 10 somewhere.
I do recognize on the other hand that the Commis-11 sion guidance did have--was rather explicit on providing us 12
' guidance on performance indicators, for example, in this ys
(,).
13 context, and we are awaiting further Commission guidance on 14 implementation.
And we're expecting this within a week or 15
.two now.
I've been saying that for several weeks.
So we'll 16 see if that sheds some light on it.
17 I don't disagree that there ought to be something 18 here on it.
How you quantify it or how long it might take 19 to produce something that is usefully quantifiable I think 20 is another question.
21 Anyway, going on to the IVA, what I call the acci-22 dent prevention objection, the ACRS suggested target was
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was that the likelihood of loss of' assured core cooling.was 5
probably a good' deal greater than " core-on-the-floor."
You-6 said.it the other way around but--
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12 parts of.10-4' loss of assured core cooling and then an addi-(q 13 tional target for " core-on-the-floor" given loss.of assured
,j 14 core cooling.
15 Now, the attractiveness, if it in fact be attrac-16 tiveness, of having such a target is that we are embarked on 17 the staff of a program to try to develop guidance, if you 18 will, for licensees under the banner headline of Accident-19 Management.
Or again, to use an industry term, core stabili-20 zation.
That is, recognizing that you might get into situa-21 tions at a plant where you begin to get some degradation of 22 the core but you would like to have procedures available, f-)
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I suspect that we cannot with 5
any great accuracy.
But it might be useful to have that as a 8
target.
7 The current state-of-the-art does not model well 8-I really should say.
It makes an attempt to model.
Some 9
core melt' progression phenomena to permit-the calculation 10 for a comparison, and to repeat.what I just said,.it may al-l 11 ready be a useful target for accident management.
12 Now, for the containment performance, the ACRS (Av,)
13 recommendation was a 10-1 large release.
I presume large 14-release given loss of assured core cooling, which as I read 15 the ACRS letter gives you a 10-5 overall, which I didn't 16 understand.
17 MR. REMICK:
10-1 for a large release.
18 MR. HOUSTON:
I don't think you used the term 19 "large release."
You may have used the term " conditional 20 containment failure."
21 MR. REMICK:
I thought we were assuming " core-on-22 the-floor" when we said that.
I su're was.
I saw that consis-s 23 tent with 10-6, I^T 24 MR. HOUSTON:
Well, what it says is "we recommend V
25 as a minimum the containment performance objectives to be
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At least.
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At least.
You see what I mean?
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Yes, I understand what you mean.
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You said -thi's. is t the ~ defense -in-depth--
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I don't understand why.not.
18 MR. HOUSTON:
Well,'I understood one of the cri-19
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?
21-MR. KERR:
Yes.
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Yes.
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Now, if the previous level was 10-6 l
24 frequency of the large release, then I was looking for con-25 sistency with that.
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5 MR. HOU.'; TON :
It's independent.
All right.
That's 6
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another way to look at it?
8 MR. WARD:
No.
I think it's a wayLof getting a-9.
defense-in-depth.
10 MR. KERR:
If you define conservatism and' defense-11 in-depth to be synonymous, yes.
12 MR. HOUSTON:
They are not precisely synonymous, (n)-
13 MR. KERR:
No.
w-14 MR. HOUSTON: They are not synonymous.
15 MR. KERR:
We were not thinking of conservatism.
16.
We were thinking of defense-in-depth.
17 MR. HOUSTON:
Okay.
That's interesting.
I had not 18
- read it that way.
That's useful.
10 MR. KERR:
And as you read it, I can see that one 20 might--we write these things after talking about them a lot 21 and sometimes we leave out some of the things we say.
22 MR. WARD:
But, see, the argument is that even if t,_3 '
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23 Should have a higher level of confidence.
That's not a 24 quantified--
25 DR. OKRENT:
If you put a period after " future j
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Arid I suspect: and what we really should' do 14 is: undertake a more' thorough evaluati'on of some sort with' X )'
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You'd better finish up.
4 MR. HOUSTON:
Page 14 was just some plants sampling 21 22 programs.
We generally agree with the recommendations, at least in the sense that to us the sampling program refers
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program not to exclude PRA type of information coming from J
2 utilities, such as through an IPE Program.
We tend to think 3
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1400 revisited and enlarged.
And we do have plans to, on the 5
follow on, to deal with the external events for Peach Bottom 6
and Surry.
I don't think they are going to appear in the 7
same volume of 1150.
It might be 1150A or something like 8
that.
9 Lasalle will appear six to eight months later to 10 complete the set of BWRs.
And then a B&W plant and a CE 11 plant, which have not been selected yet.
12 We do not have good criteria for sampling and if lh 13 had some suggestions on this, why we would be delighted to 14 hear them.
15 MR. WARD:
I think--well, at least my interpreta-10 tion of what the Committee meant was to use all the data 17 that are available as far as sampling.
It might be a con-18 tinuation of 1150 if you think that's necessary.
But make 19 use of other information as it becomes available.
You have 20 to consider the quality of it and the limitations of it.
21 But more importantly, it's what are you going to 22 do with that?
Your sampling.
And that gets back to the L) 23 issue of--
('T 24 MR. HOUSTON:
Why 1150?
w) 25 MR. WARD:
No, no.
To me it gets back to the issue l
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Some elements of the staff'would agree.withL hat.
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for; example,. and'say, "Oh, my goodness.
This tell's'us that.
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19-It raises questions because issues have' arisen.
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'2 MR. WARD:
It would seem to me--what I would like 3
to see is the staff develop a program plan to--you know, 4
there's talk about this hiatus in licensing.
It seems like 5
an opportunity'to revisit even the general design criteria, 6
for example.
Which of those contribute to getting the plant.
7 that will meet the Safety Goal.
Which don't do enough.
And 8
which are unnecessary.
Sort of take those as holy writ and 9
now we've got a new mechanism for testing how holy they are.
10 MR. HOUSTON:
Well, I must say at the present time 11 I think it would be very difficult or not possible for us 12 to say, "Yes, we have a plan to do that."
One can see things lh 13 that are in the works, so to speak, that could be tied into 14 such a plan.
But a plan to do exactly what you're saying is 15 not at the moment--does not exist at the moment.
And I don't 16 think we've really thought about it enough.
It's hard for me 17 to respond.
18 MR. WARD:
But that's what our letter is suggest-19 ing.
20 MR. HOUSTON:
But that's what your letter is 21 suggesting, yes.
Okay.
It is more of a direct frontal 12 attack kind of thing.
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Can I make a comment concerning
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The Commision sometime back in the Severe Accident U
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6 I think that was certainly a motivation.
Not the only one.
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' reactors."
10 It seems to.me that one needs to ask the question I oes the Commission need to have some better aasessment than 11 d
12 it now has of--if you want to call it the integral level of JT l:v) 13 safety, from all the plants, or however you want to speak of 14 it. -
15 Is the current information that it has really ade-16 quate for it to.just sit still and not try to ascertain in 17 a better way what is the level of safety that exists?
If 18 it decides it's okay, you don't need to do any more sampling.
19 If you think in fact that there's a reason to have a better 20 basis, I would say what you are showing on page 14 is much 21 too little and one would have to think what kind of a program 22 might give--while not a truly complete sample, a sample that f,i,I m'
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25 MR. HOUSTON:
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least partial response to that comment or question.
There j
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are people on the staff, for example, who feel that with the 3
p'assage of time since the Severe Accident Policy Statement 4
was set forth and identified on the one hand that generally 5
reactors were safe enough, but PRAs do tell us that variations 6
that are quite plant specific can produce vulnerabilities 7
in certain plans to spawn the IPE program, but a consideration g
at that time is it's unreasonable to--for a number of reasons, 9
to requ' ire all licensees all of a sudden to do.PRAs on their i
10 plants.
A practical reason is that there are not that many 11 PRA analysts in the country that can actually do this in a 12 moderately short period of time like a couple of years.
13 Hence, the so-called smart PRA or IPE, as it's now called.
14 With that passage of time, the cost of doing a l
15 PRA has come down.
And as a matter of fact, it's my under-16 standing that at the present time you can do a good PRA on 17 a plant at about the same cost that you use the id core 18 methodology, IPE methodology.
So there are people on the.
staff who feel that really the thrust of the IPE program 39 20 should be changed from its present thrust of an IPE-type of an examination towards in effect telling them to go out and 21 22 do a PRA.
And that would be at least in part an attempt--
L j a source of information of the type that I think you are 23 talking about.
Now, whether that will come to pass or not U
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And if the plant management and opera-
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,4 MR. HOUSTON:
True, true, yes.
5 MR. WARD:
Sounds wonderful, doesn't it?
6 DR. OKRENT:
Are there any other further points?
,j 7
- MR. HOUSTON
I mean I had two more pages, but I'm 8
willing to stop'here.
y 9
'DR.
OKRENT:
I think it's getting sort of late.
10
.Any comments?
Do I recall that this-is on the' 11 agenda for the full committee?
12 MR. HOUSTON:
Not this one.
~n 13 DR. OKRENT:
You will presumably sometime in the (y) 14 futuro. advise the commitcee--
15
- MR. HOUSTON
We expect to prepare the next step 16 over the course of the next weeks, perhaps one to two 17 months, re the preparation of a revised staff implementation IP plan.
It will probably take the form of a Commission paper 19 ultimately, but at some point.
I'm not quite clear that we 20 will be ready for the November meeting but certainly hope-
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21 fully by the December meeting.
I think we would have some-22 thing that we would provide, like a draft for the Subcommittee (3
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And perhaps then we'll talk to the full commit-S 24 tee.
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Sounds fine.
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3 This 1s to' certify _that the attached' proceedings before_the 4
United States Nuclear Regulatory Commission in the matter of:
5 Name: Advisory Committee on Reactor Safeguards-Subcommittee on Safety Philosophy, Technology 6
and Criteria 7
Docket Number:
8 Place:
Washington, D.C.
9 Date:
October 7, 1987 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States' Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction
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14 of the court reporting company, and that the transcript is a 15 true and accurate record of the fore ing proceedings.
16
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Irwin Coffenberry 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 l
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